l\L,c:,c(JUo-jaj Guide 60 Upstream Petroleum Industry Flaring, Incinerating, and Venting December 2002 Draft Alberta Energy and Utilities Board I I Guide 60 Upstream Petroleum Industry Flaring, Incinerating, and Venting December 2002 Draft ALBERTA ENERGY AND UTILITIES BOARD Guide 60: Upstream Petroleum Industry Flaring, Incinerating, and Venting Guide - D RAFT December 2002 Published by Alberta Energy and Utilities Board 640 - 5 Avenue SW Calgary, Alberta T2P 3G4 Telephone: (403)297-8311 Fax: (403) 297-7040 Web site: <www.eub.gov.ab.ca> DRAFT Contents 1 Introduction 1 1 . 1 Purpose of This Guide 1 1.2 Flaring, Incinerating, and Venting Management Hierarchy and Framework 1 1 .3 Access to Production Flaring, Incinerating, and Venting Data 2 1 .4 How to Use This Guide 2 2 Solution Gas Management (Crude Oil/Bitumen Battery Flaring, Incinerating, and Venting) 3 2.1 Solution Gas Flaring Reduction Targets 3 2.2 Solution Gas Venting Reduction 3 2.3 Solution Gas Flaring and Venting Decision Tree 4 2.4 Conservation at Oil and Bitumen Batteries 4 2.4.1 Solution Gas Flares and Vents at New Oil/Bitumen Wells 5 2.4.2 Solution Gas Flares at Existing Oil/Bitumen Batteries 6 2.4.3 Solution Gas Vents at Existing Oil/Bitumen Batteries 6 2.4.4 Delays in Implementing Conservation 7 2.5 Clustering 7 2.6 Power Generation Using Otherwise-FlaredA^ ented Gas 8 2.7 Economic Evaluation of Gas Conservation 8 2.7.1 Economic Evaluation Assumptions and Parameters 8 2.7.2 Economic Evaluation Data 10 2.8 Consultation and Notification 10 2.8.1 Public Information Package 10 2.9 Dealing with Public Concems/Objections 11 2.10 Flaring, Incinerating, and Venting at Conserving Facilities 1 1 2.10.1 Limitations on Nonroutine Flaring, Incinerating, and Venting During Conserving Facility Outages..... 1 1 2.10.2 Planned Shutdown (Turnaround) Considerations 12 2.10.3 Variance to Solution Gas Shut-in Requirements 13 2.11 Royalty Treatment of Flared and Vented Gas 13 2.12 Solution Gas Reporting Requirements and Data Access 13 2.12.1 S o lution Gas Reporting Requirements 13 2.12.2 Data Access 14 2.12.3 Third-Party Access to Data 14 3 Temporary and Well Test Flaring and Incinerating 15 3.1 Gas Well Test Flaring and Incinerating Decision Tree 15 3.2 Temporary Flaring/Incinerating Permits 15 3.2. 1 Conditions That Require a Temporary Flaring/Incinerating Permit 1 6 3 .2.2 Conditions That Do Not Require a Temporary FlaringAncinerating Permit 1 7 3 .3 Flaring and Incinerating During Underbalanced Drilling 18 3.4 Permit Application Requirements for Temporary Flares and Incinerators 19 3.4.1 General Permit Application Requirements 19 3.4.2 Applications to Exceed the Routine Flare Volume Allowance 19 3 .4.3 Blanket Flaring/Incinerating Permits 21 3.4.4 EUB Review of Permit Applications 22 3.5 Ambient Air Quality Evaluation (Dispersion Modelling) 23 3.5.1 Well Test Incinerator Modelling Requirements 24 3 .5 .2 Well Test Air Quality Management Plans 24 (continued) EUB Guide 60: Upstream Petroleum Industry Flaring, Incinerating, and Venting (December 2002 Draft) • i DRAFT 3.6 Site-Specific Requirements Related to Well Flaring and Incinerating 24 3.7 Temporary Facilities for In-Line Tests 25 3.8 Notification and Consultation Requirements 27 3.8.1 Addressing Issues and Public Concerns 28 3.8.2 Resolving Public Concerns and Obj ections 29 3.8.3 EUB Flaring/IncineratingA^ enting Notice Form 30 3.9 Reporting Gas Well Test Data 30 4 Gas Battery Flaring, Incinerating, and Venting 3 1 4. 1 Gas Battery Flaring, Incinerating, and Venting Decision Tree 31 4.2 Notification 31 4.3 Reporting .....32 5 Gas Plant Flaring, Incinerating, and Venting 34 5 . 1 Gas Plant Flaring, Incinerating, and Venting Decision Tree 34 5.2 Gas Plant Flaring Volume Limits 35 5 .3 Frequent Flaring Events 35 5.4 Notification 36 5.5 Reporting 36 6 Pipeline Flaring, Incinerating, and Venting 38 6. 1 Pipeline Systems Flaring, Incinerating, and Venting Decision Tree 38 6.2 Additional Requirements for Gas Gathering Systems 3 9 6.3 Application of Guide 60 to Natural Gas Transmission Systems 40 6.4 Notification 40 7 Gas Combustion Requirements 42 7.1 Minimum Combustion Efficiency 43 7.2 Visible Emissions 43 7.3 Flame Stability and Minimum Heating Value for Acid Gas Flares 44 7.4 Flare Ignition 45 7.4. 1 Application for Extinguishing Flare Pilots at All Batteries 45 7.5 Stack Height 46 7.6 Emergency Sour and Acid Gas Flaring/Incineration Procedures 47 7.7 Liquid Separation , 48 7.7. 1 Exceptions to Flare Separator Requirements 49 7.8 Backflash Control 49 7 . 9 Flare and Incinerator Spacing Requirements 49 7.10 Compliance with Fire Bans 51 7.11 Noise 51 7.12 Portable Flare and Incinerator Units 51 7.13 Supplemental Requirements for Incinerators and Enclosed Burners 51 7.14^ Flare Pits 52 7.15 Dispersion Modelling Requirements for Sour and Acid Gas Combustion 53 7.15.1 Modelling Assumptions 53 7. 1 5 .2 Individual Source Modelling Approach 54 7.15.3 SO2 Cumulative Emissions Assessment 55 8 Venting and Fugitive Emissions Management Requirements 56 8.1 General Requirements 56 8.2 Limitations on Venting Gas Containing H2S or Other Odorous Compounds 57 8.3 Limitations on Venting Gas Containing Benzene 57 8.4 Fugitive Emissions Management 57 8.5 Limitations on Venting in Heavy Oil/Oil Sands Operations 58 8.6 Limitations and Guidelines for Well Test and Maintenance Venting 58 (continued) ii • EUB Guide 60: Upstream Petroleum Industry Flaring, Incinerating, and Venting (December 2002 Draft) DRAFT 8.7 Venting of Noncombustible Gas Mixtures 59 8 . 8 Coalbed Methane Venting 60 9 Sulphur Recovery Requirements and Sour Gas Combustion 61 9.1 Sulphur Recovery Exemption at Solution Gas Conservation Facilities 61 10 Measurement and Reporting 63 10.1 Metering Requirements and Guidelines 64 10.2 Estimating Requirements 65 10.3 Treatment of Gas Well Production Delivered to Oil Batteries 65 10.4 Flared, Incinerated, and Vented Gas Reporting 66 10.5 Flaring, Incinerating, and Venting Records (Logs) 66 1 1 Industry Performance Reporting 68 12 Compliance and Enforcement 69 12.1 Unsatisfactory Items 69 Appendices 1 References and Contacts Cited 73 2 Definitions as Used in Guide 60 75 3 Abbreviations 77 4 Background to Guide 60 78 5 Flaring/Incinerating Permit Application Requirements 79 6 Flaring/Incinerating Permit Application Form 82 7 Application Information for Routine Flare Volume Exceedance for Well Test and Underbalanced Drilling (600, 400, or 200 10^ m^ Exceedance) 83 8 Simplified Sour Flare Assessments for Parallel Air Flow Conditions 84 9 Complex Terrain and Refined Dispersion Modelling 86 10 Well Test Air Quality Management Plans 88 1 1 EUB Flaring/IncineratingA^ enting Notice Form 90 12 Sour Gas Flaring/Incinerating Data Summary Report 94 13 Application to Extinguish Sour Gas Flare Pilots 95 14 H2S Odour Management Process 97 Figures 1 Solution Gas FlaringA/^ enting Management Framework 2 2 Solution Gas Flaring/V enting Decision Tree 4 3 Well Test Flaring and Incinerating Decision Tree 16 4 Temporary Flaring/Incinerating Permit Application Process 19 5 Facility Flaring, Incinerating, and Venting Decision Tree 32 6 Pipeline Flaring, Incinerating, and Venting Decision Tree 39 Tables 1 Limitations on nonroutine flaring, incinerating, and venting during conserving facility outages 12 2 Well test and maintenance flaring and incinerating notification requirements 28 3 Major flaring event definition 35 4 Unsatisfactory Items 70 EUB Guide 60: Upstream Petroleum Industry Flaring, Incinerating, and Venting (December 2002 Draft) • iii DRAFT 1 Introduction 1 .1 Purpose of This Guide The Alberta Energy and Utilities Board (EUB) Guide 60: Upstream Petroleum Industry Flaring. Incinerating, and Venting provides regulatory requirements and guidelines for flaring, incinerating, and venting in Alberta, as well as procedural information for flare permit applications, dispersion modelling, and the measuring and reporting of flared, incinerated, and vented gas. In addition to upstream petroleum industry facilities, the guide also appUes to gas transmission facilities licensed by the EUB. This revised guide supersedes the previous edition of Guide 60 (1999) and all editions of Guide 60: Updates and Clarifications (1999 and 2001). As a result, Interim Directive (ID) 99-06, which introduced Guide 60 (1999), is also rescinded. This guide incorporates new requirements for the evaluation of solution gas venting and the reporting of economic evaluation data on solution gas flares and vents as described in General Bulletin (GB) 2002-05: EUB Requirements for Evaluation of S olution Gas Vent Gas Conservation. 1 .2 Flaring, Incinerating, and Venting Management Hierarchy and Framework Flaring, incinerating, and venting are associated with a wide range of energy development activities and operations, including disposal of gas associated with • oil, bitumen, and gas well drilling, • oil, bitumen, and gas well completion or well servicing (well "cleanup"), • gas well testing to estimate reserves and determine productivity, • oil or bitumen production (solution gas), • nonroutine maintenance or emergency depressuring of gas pipelines and processing plant facilities, and upstream petroleum industry waste management facilities. Two multistakeholder teams from the Clean Air Strategic Alliance (CASA) have made recommendations on flaring, incinerating, and venting for the upstream petroleum industry upon which the EUB has based Guide 60 (see Appendix 4 for background on Guide 60). In particular, the EUB has adopted CASA's objective hierarchy and its fi-amework for the management of routine solution gas flares (Figure 1) a nd has extended its application to include flaring, incinerating, and venting of gas in general (see also CASA's 1998 Management of R outine Solution Gas Flaring in Alberta: Report and Recommendations of the Flaring Project Team). The objective hierarchy suggests that licensees ask the following three questions: Can flaring, incinerating, and venting be eliminated? • Can flaring, incinerating, and venting be reduced? Will flaring, incinerating, and venting meet performance standards? EUB Guide 60: Upstream Petroleum Industry Flaring, Incinerating, and Venting (December 2002 Draft) • 1 DRAFT Cannot reduce Figure 1 . S olution Gas Flaring/Venting Management Framework (adapted from CASA) 1 .3 Access to Production Flaring, Incinerating, and Venting Data The EUB makes flaring, incinerating, and venting information available to licensees in order to facilitate solution gas conservation and clustering opportunities, as described in Section 2.12. 1.4 How to Use This Guide EUB requirements and recommended practices are numbered sequentially within each section and subsection throughout Guide 60. In general, "must" indicates a requirement, and "recommends" and "expects" indicate a recommended practice. To assist the reader. Appendix 1 lists references and contacts cited. Appendix 2 lists definitions of terms used, and Appendix 3 lists acronyms and abbreviations used throughout the text. 2 • EUB Guide 60: Upstream Petroleum Industry Flaring, Incinerating, and Venting (December 2002 Draft)